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Issues: Whether the Assistant Charity Commissioner, Greater Bombay had jurisdiction to issue directions concerning the administration of a trust whose office was situated in Gujarat but whose properties were partly in Maharashtra.
Analysis: The governing scheme and the regional reorganisation order showed that the trust stood registered in Gujarat because its office of administration was there, while only the properties situated in Maharashtra were deemed to be registered in Maharashtra region. The statutory scheme did not confer authority on the Bombay Charity Commissioner to control the entire trust merely because some assets lay within Maharashtra. The doctrine of lex situs and the principle of territorial nexus limited the reach of the Bombay authority to the property within Maharashtra. Directions affecting the whole trust, including the administration of the trust as a whole, could not therefore be issued by that authority. The conduct of the trust in filing some documents before the Bombay office did not cure the want of jurisdiction.
Conclusion: The Assistant Charity Commissioner, Greater Bombay lacked jurisdiction over the administration of the entire trust and could exercise authority only in relation to the property situated in Maharashtra; the impugned directions could not be sustained.
Ratio Decidendi: Where a trust's office of administration is situated in one State, a statutory authority in another State can act only to the extent expressly permitted by the applicable regional reorganisation scheme, and jurisdiction over the whole trust cannot be assumed merely because part of the trust property is located within that State.